Human Trafficking Disclosure – What Do Smoot And Hawley Have To Do With It?


Last February, I wrote this post about SB 657, the California Transparency in Supply Chains Act of 2010. This legislation will take effect on January 1, 2012 and will require retail sellers and manufacturers doing business in California to disclose their efforts to eradicate slavery and human trafficking from their supply chains for tangible goods offered for sale. Cal. Civ. Code § 1714.43(a). To be subject to this new requirement, a retail seller or manufacturer must have annual worldwide ”gross receipts” that exceed $100,000,000. The Act includes definitions of ”doing business in this state”, “gross receipts”, “manufacturer” and “retail seller”.

Because only the California Attorney General is vested with the authority to enforce the Act, I recently submitted a Public Records Act request for copies of all correspondence to and from the Attorney General’s office regarding implementation of the act. As might be expected, several companies, trade groups and lawyers are seeking guidance from the Attorney General’s office. However, the Attorney General’s office doesn’t seem to have any plans to issue guidance, furnish sample disclosures or provide feedback on proposed disclosures. In fact, I can’t find any reference to the act on the Attorney General’s website. Senator Darrell Steinberg, the author of SB 657, did convene a small roundtable discussion in July “to help us better understand what sorts of expectations might be reaonable in terms of compliance.”

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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